Simon Walker, Founder and Director of SJW Enviro Consulting Ltd, explains the process of applying for the correct environmental permits when setting up an Authorised Treatment Facility (ATF).
Since 1988 the regulation and permitting of Authorised Treatment Facilities (ATF) for the dismantling and depollution of end-of-life vehicles has been controlled by the Environment Agency and its predecessor organisations in England.
Starting an ATF from scratch in 2022 can be complicated, time-consuming and expensive. However, operating without the correct permits and permissions could leave individuals or organisations open to prosecution, significant fines, and in severe cases, a custodial sentence.
The following looks at what is required to obtain a permit for a new ATF from the Environment Agency (EA):
It does not consider planning permission which may need to be sought from the local authority, or registration under the Scrap Metal Dealers Act which also comes under the local authority remit.
The first thing you need to know is that a permit doesn’t appear overnight. Current backlogs with the permitting system at the EA means that it could be up to 12 months before a permit is issued and you can start operating.
It is also strongly advised to seek professional assistance when compiling a permit application, as this could save time and money during the process.
The first decision to make is what type of permit to apply for. Here, you have two options. Standard Rules or Bespoke.
To apply for a Standard Rules permit for an ATF, your site must meet the standards and rules set out within the permit. There are two Standard Rules sets for ATF’s
- SR2015 No13 – Vehicle storage, depollution and dismantling up to 25,000 tonnes per annum
- SR2015 No17 – Vehicle storage, depollution and dismantling up to 2,500 tonnes per annum
The two sets of rules can be found at SR2015No13 and SR2015 No 17
A third Standard Rules permit also allows the storage of scrap metal (SR2015 No18), but this is not being considered here.
If you wish to process more than 25,000 tonnes per annum of vehicles or there are reasons why your facility does not meet any of the rules or requirements, then you will need to apply for a bespoke permit. A bespoke permit, on the whole, takes longer to process, is more complicated and significantly more expensive to apply for. An application for either of the two Standard Rules permits is currently £3926.00, while a bespoke permit is £8840.00.
Application forms for both types of permits can be found on the EA website at standard rules.
In addition to the application fee, it will also be necessary to submit a Fire Prevention Plan (FPP). For a bespoke permit, the EA charges a further £1241 to assess the FPP. While, for a Standard Rules application, this charge is included in the application fee.
FPPs are complicated documents and the hardest part of the application process to get right. Guidance on what the EA requires can be found on their website and in an article published by ATF Professional in March 2021; EA Fire Prevention Plan Guidance Update.
Next, consideration should be given to how the site is laid out. This includes buildings, sitting of de-pollution equipment, surfacing, vehicle storage areas, security, drainage, bunding, storage of liquids, batteries, tyres etc. All these will need to be reported to the Environment Agency at the application stage as part of an effective management system that minimises the risk of pollution. The permit, when issued, will ensure that you manage and operate activities in accordance with the management system.
Depending on the location of your ATF, the EA may also require you to submit a dust management plan, noise management plan or noise impact assessment, and there are further charges for each of these documents levied by the EA. Bespoke permit applications also require site-specific risk assessments but these do not attract an additional fee.
You will also be required to have a Technically Competent Manager (TCM) who will oversee the running of the site. To demonstrate technical competence, you must comply with one of two government-approved schemes:
- Chartered Institute of Wastes Management/Waste Management Industry Training and Advisory Board (CIWM/WAMITAB) scheme: https://wamitab.org.uk/competence/
- Environmental Services Association/Energy and Utility Skills (ESA/EU skills) scheme: https://euskills.co.uk/about/the-group/energy-utility-skills-register/
One final consideration when opening a permitted ATF. The EA charge an annual subsistence fee for the permit. This charge varies depending on the type of permit and the quantity of material processed. For the Standard Rules permits, this charge is £971 per annum for SR2015 No17 and £2567 per annum for SR2005 No13. The bespoke permit attracts an annual fee of £4006. The EA also charge an additional £672 for the first year of operation after the permit issue. They consider this to be the additional cost of providing advice and support at the start of your operation.
For further information, please contact Simon on 07471 910102 or email him at simon@sjwenviroconsulting.co.uk
